Mongolia - Licensing and Control
Summary
Since August 2025, Mongolia has a comprehensive ban on all forms of paid gambling, including online gambling, betting, "paid forecasts" and paid lotteries. The amendments approved by the Great State Khural transferred the organization and assistance to the category of criminal offenses. The previously discussed model of "point" legalization of rates (spring 2025) was finally rejected in favor of a total ban.
Legal Framework and Control Architecture (2025)
Key changes
Amendments to the Permits Act (Licensing/Permits): An outright ban on online gambling, betting and paid lotteries.
Amendments to the Criminal Code: criminal liability for organizing and assisting (including the provision of bank accounts, phone numbers, electronic wallets/" digital accounts" for transactions).
Sanctions (range): heavy fines, 240-720 hours of compulsory work, travel restrictions (up to 1 year), or imprisonment for 6-36 months - for compositions for "paid forecasts/rates/online gambling."
Online and payment locks
The state declares blocking the sites/applications of casinos and bookmakers and blocking the final channels to them. Responsibility extends to intermediaries/" agents" providing infrastructure for settlements and communications.
What is directly prohibited
Online casinos, poker, slots, bingo, skin betting, etc. (in any form).
Sports/esports betting - both offline and online (including "paid forecasts").
Paid lotteries and paid "predictive" products (prediction, sweepstakes for a fee).
Advertising, attraction and assistance (affiliates, lead generation, acceptance/routing of payments, provision of accounts).
Historical context: from plans to ban
Casino Law 1998: The law was repealed shortly after passage; the government re-issued the new casino draft in 2023 as part of a tourism campaign, but further legalization did not take place.
Spring 2025: A regulated betting model was discussed, while maintaining the casino ban; by August, the course changed to a complete ban (including betting and paid lotteries).
Risks and enforcement
Extraterritoriality in practice: the participation of Mongolian residents in offshore products, as well as the acceptance/conduct of payments in favor of such services are considered as complicity and are suppressed.
Content and advertising: landing pages, promos, mirrors, telegrams/social stores, coupons and referral networks are subject to assistance.
Payment intermediaries: banks, fintechs, crypto platforms and exchangers bear an increased risk through AML/sanctions and criminal law for facilitating illegal games.
Compliance checklist (high-level)
1. Zero targeting of Mongolia: interface language, domains, ASO/SEO, advertising, influencer activity, UGC communities - to be excluded.
2. Payment filters: block MCC/routes, P2P schemes and crypto "bridges" in favor of gambling services; Store lock audit trails.
3. Content moderation: Remove reflinks/" mirrors," paid predictions, and crawl training materials.
4. Yur. position: rejection of any B2B contracts for gambling products in Mongolia; lack of legal licensing = inability to operate legally.
Prospect
Until the end of the decade, the vector is a tough protectionist policy with zero tolerance for gaming products. Attempts at targeted legalization (for example, only sports betting) in 2025 were rejected - as a result, a comprehensive ban with criminal liability and technological locks was adopted. Any activity in the gambling market in Mongolia is now unrealizable in the legal field.
Terms
"Paid forecasts" - any predictive/gaming services for a fee equated to betting/gambling.
Ban on "assistance" - criminal liability for the provision of bank accounts, telephones, e-money/crypto wallets for organizing illegal games.